Towards a new London Plan: utilising green belt and Metropolitan Open Land for development

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Towards a new London Plan: utilising green belt and Metropolitan Open Land for development

London’s green belt land is currently heavily protected – more so than even national policy provisions. The proposals set out in the London Mayor’s ‘Towards a new London Plan’ document signal a dramatic shift, falling in line with the government’s new, more pragmatic, approach to the green belt.

The messaging is clear – the Greater London Authority (GLA) will explore the potential release of parts of the green belt for development, particularly land that is low quality, poorly maintained and rarely enjoyed by London residents. This is a marked change from the position taken in the current London Plan.

The reason for this approach is clear – there is simply insufficient land outside the green belt to deliver the growth required over the coming years. The document sets out that the new London Plan will need to deliver 88,000 dwellings per annum (dpa) alongside delivering increased industrial, data centre, energy and other infrastructure capacity in the right locations. The figures ratify this – the average net additional dwellings delivered over the last three years is circa 36,000 dpa – well short of the current London Plan target of 56,000 dpa and over 50,000 dpa below the forthcoming annual requirement. More needs to be done, including developing on some green belt land.

Of course, this does not mean the entire green belt will be considered suitable for development, and new development in these locations will be expected to maximise the level of affordable housing, ensure high-quality housing design, good transport connectivity and increase biodiversity and access to good-quality green spaces. There is mention of a new generation of enhanced or new public parks for Londoners subject to funding. It is not apparent yet whether these requirements will go above and beyond existing policy requirements/the golden rules.

Where will development be directed?

The document confirms that a strategic review of green belt land will be undertaken across London. The Mayor has made it clear that any green belt released as part of the London-wide review should be sustainably located, with good public transport access (or where this could feasibly be delivered). The strategic review will also identify ‘grey belt land’ across London – a concept introduced by the National Planning Policy Framework (NPPF) in December 2024 and it being green belt land that does not contribute strongly to three of its purposes where policy allows for larger-scale development in certain circumstances.

The GLA will be engaging with the New Towns Taskforce to see whether there are any opportunities to deliver large urban extensions (10,000 plus homes) within the green belt. Again, emphasis is placed on transport links as they explore, at a strategic level, potential new public transport, for example new stations, increasing rail frequencies and extending existing lines (e.g. the Bakerloo line).

With regard to industrial land, there may be opportunities to provide additional, or swap (with housing sites), industrial capacity in the grey belt, especially in locations that are less suitable for housing. This could be in areas with high noise levels or better connections to the road network rather than public transport.

What about Metropolitan Open Land?

Many in the industry have been questioning whether the grey belt approach applies to Metropolitan Open Land (MOL) as the current iteration of the London Plan links MOL to national green belt policy. Presumably this was to give it the highest level of protection, however the introduction of the grey belt has somewhat relaxed such policy provisions for certain areas of MOL. 

The Mayor has stated in the document that MOL performs a vital role for Londoners, and will become even more important as more homes are built. So the new London Plan is expected to distinguish between MOL and green belt in specific aspects of policy approach. Nevertheless, some areas of MOL that undermine the designation’s purpose could be released, such as certain golf courses which are not accessible to the wider public and have limited biodiversity value.

There could be an influx of applications on MOL sites that meet the grey belt definition to try to get approval before the new London Plan is adopted. 

Where should developers be looking?

In light of the above, it is apparent that the most viable sites within the green belt/MOL will be those in highly sustainable locations with good public transport links. Transport for London (TfL) uses Public Transport Accessibility Levels (PTAL) as a measure of how accessible sites and areas are. It is noted that the document suggests PTAL may eventually be replaced by a new methodology; however, at present, it remains a valuable tool for identifying sustainable development sites.

As shown below, Savills Research has a mapping system which can overlay green belt/MOL onto PTAL clearly showing the areas/sites that developers should be targeting. Once identified, there could an opportunity to promote the land under the current Local Plan consultations, which could help inform the forthcoming green belt review.

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Source: Savills Research using TfL PTAL

 

Further information

Contact James Callaway or Matt Richards 

 

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